Section 148 Notice for reassessment invalid If not served properly

Harjeet Surajprakash Girotra Vs UOI & Ors. (Bombay High Court) Conclusion: Since the delivery of the notice of reassessment could not be made at the address of assessee available in PAN database, by virtue of the further proviso to sub-rule (2) of Rule 127, the communication had to be delivered at the address as available with the banking company however, no such steps were taken, therefore, service of notice was not complete and reopening of assessment was invalid. Held: Assessee–individual was a widowed lady had never filed return of income since she did not have any taxable income...